Background-Dossier Romanian National Parks

OUT OF CONTROL THE UNFOLDING TRAGEDY OF ROMANIA’S NATIONAL PARKS

Background dossier, December 2017

October 2017: Radoteasa valley, Domogled - Valea Cernei National Park. © Matthias Schickhofer

1. THE OUTSTANDING NATURAL HERITAGE OF ROMANIA’S PRIMEVAL FORESTS UNDER ATTACK

Primeval forests have almost totally disappeared from Europe’s map. Only in the Carpathians, the Dinaric Alps and the Balkans have large, untouched areas of forests survived until the present day. The majority of this outstanding natural treasure is located in the Carpathians, a sweeping 1,500 km long range of mountains in central and eastern Europe. Two thirds of Europe’s primeval forests are found in the Romanian Carpathians, where an estimated area of over 200,000 hectares of virgin forests remains, providing homes to a myriad of important plants and animals. Romania is home to Europe’s most abundant populations of large carnivores, including bears, wolves and lynx. In 2016, the Romanian addition made up the largest individual country share of an extension to the UNESCO Ancient and Primeval Beech Forest World Heritage site. 1

Mainly located in remote mountain areas and steep valleys, the relative inaccessibility of these ancient forests has thus far saved them from destruction. However, the insatiable appetite of the logging industry now threatens the survival of the European Union’s largest and most precious remains of primeval forests. Tens of thousands of hectares have been destroyed in Romania in the past decade alone. Logging roads now dissect some of the last untouched valleys and slopes. Good governance is non-existent and protection programs are completely failing these forests. Logging proceeds at a high pace.

In Romania, Europe's largest nature conservation drama is rapidly unfolding, with almost nobody taking notice or action. National Parks are not immune to the onslaught and most have been severely degraded with some already resembling commercial logging sites, not special places protected for their natural wonder. This is happening before the eyes of the Romanian Government and the European Union. This scandalous destruction of some of Europe’s most valuable natural heritage must end. The EU and the Romanian government must take immediate action to save these irreplaceable remaining wild forests.

Intact but unprotected primeval beech forest, Radoteasa valley, Domogled Nationalpark. © Matthias Schickhofer

2 2. DEVASTATION OF FORESTS IN ROMANIA’S NATIONAL PARKS

Unbeknown to most people, Romanian national parks are the subject of intensive and extensive logging. In most national parks, centuries old trees are being systematically logged for commodity products such as firewood and pulp. “Protected areas” are commercially logged, destroying large areas of precious, biodiversity rich primeval forests.

Almost all national parks in Romania fail to meet international conservation criteria, which are supposed to prioritise conservation objectives within management plans and forbid industrial exploitation of resources. Large areas of forests within Romanian national parks are simply commercial logging sites, which do not differ from industrially logged forest zones outside the protected areas. Logging is happening with approval of the national park administrations and with full sanction of the Romanian Government.

The problem of Romanian national parks in a nutshell:

- The purpose of a National Park is to protect natural biodiversity (IUCN Category II), actioned through the designation of strictly protected core zones, which should be large (at least 75 per cent of the park’s surface) and interconnected. In Romania the core zones are often small and appear as isolated fragments. In most cases they do not comply with international best practice criteria as set up by the International Union for the Conservation of Nature (IUCN). - In national parks, nature conservation has to be the overall priority objective for the entire protected area. However, in Romania, nature conservation is only given priority in the much smaller core zones. The rest of the parks, including the “buffer zones”, are subjected to intensive commercial logging. These “buffer zones” do not differ from areas outside the parks, which is in clear contradiction with the international criteria as defined down by IUCN. - Primeval and old growth forests have become extremely rare in Europe. They are a very valuable natural heritage and deserve strict and long-term protection. In Romanian national parks these precious forests are only partly protected. Vast areas of primeval and old growth forests are not included within core protection zones. These forest stands in the “buffer zones” are being logged systematically, with state sanctioned approvals. - The issue of forest protection within national parks has been debated for many years in Romania. Nevertheless logging of untouched forests in national parks and other protected areas continues. And there is no change in sight. The current government has not show any commitment to improve protection of this important natural heritage of Europe.

“Buffer zone” of Domogled National Park. © Matthias Schickhofer

3 3. MISMANAGEMENT BY ROMANIAN STATE FORESTRY ROMSILVA

At the core of the tragedy of Romania’s national parks, one name is frequently mentioned: state owned forestry agency, Romsilva. 22 of 29 administrations of the country’s national and natural parks are managed under the administration, financing and control of Romsilva. All administrations of these parks are subordinated directly to the Protected Areas Service department within Romsilva. Romsilva approves minimum annual budgets for “their” parks for the basic functioning of the administration bodies. This includes personnel costs, some minimum costs for transportation, consumables and durable goods, but little or no money is allocated for real conservation measures, for ecological reconstruction or for co-financing of projects. If a park administration wants to conduct such activities, they have to seek approval of the Romsilva Board of Directors.

Until now, no secure, long term public funding has been provided directly by the Ministry of Environment (or other public bodies) for any protected area administration or their custodians. The Ministry of Environment, however, recently claimed that the government has allocated sufficient money for nature protection in the Sector Operational Program for Environment, where park custodians / administrators of the protected areas can apply for funding. But it is not easy for a custodian or a small administration structure to prepare an eligible project which has a chance of getting accepted.

Romsilva is intent on maintaining complete control of all operations within national parks: all deliverables of projects have to be approved by the Romsilva General Manager. Even the national park management plans have to be accepted by the Romsilva General Manager before they are sent to the Ministry of Environment for approval.

For some parks, Romsilva did not accept the proposed management plan - which defined the internal zoning and management measures - for more than 5 years. In the case of Semenic-Cheile Carasului National Park the management plan has still not been accepted by Romsilva, even though it is already in its 24th version. Their key rejection is often the size of the strictly protected core zone. Romanian conservationists have reported that Romsilva deliberately keeps core zones to a minimum in order to continue logging, including in virgin forests and old growth forests.

Romsilva also has responsibility for hiring and firing of national park directors. It has been reported that directors are frequently changed when they do not serve the desires of the respective forests administration (forests districts, forests directorates and Romsilva Headquarters).

Silviu Constantin was president of the Scientific Counci of Semenic National park and removed by Romsilva and Ministry of Environment after expressing critical opinions1.. Romsilva influenced membership and directed removals of members, who were critical eg.. regarding the level of cutting in the national parks forests. Informants say, that staff in the Protected Areas department with Romsilva was the origin of the removals of members Scientific Committees in some cases. There are also reports by former members that Scientific Committees have been bypassed and ignored completely by the management of some national parks.

1 Minister Order 2567/2016

4 4. WHAT ARE NATIONAL PARKS? THE GLOBAL STANDARDS

National Parks exist to protect nature in perpetuity. They are clearly defined, and mapped spatial areas set aside from exploitation to protect and conserve territories representative of the national biogeographical space, including natural elements of particular value in the physico-geographic, floristic, fauna, hydrological, geological, paleontological, speleological, pedological or other nature. They offer the possibility of visiting for scientific, educational, recreational and tourism purposes. The management of national parks must ensure the maintenance of the physio-geographic framework in a natural state, the protection of ecosystems, the conservation of genetic resources and biological diversity under conditions of ecological stability and the prevention and exclusion of any form of exploitation of natural resources and of land use incompatible with the assigned purpose. Only non-invasive traditional activities practiced by local communities should be permitted. These activities should be documented and regulated by the park’s management plan.

WHAT IS IUCN AND WHAT DOES IT RECOMMEND TO THE STATES OF THE WORLD WITH REGARD TO NATIONAL PARKS?

Founded in 1948, the IUCN (International Union for Conservation of Nature) is an international organisation dedicated to the conservation of the world’s natural resources. IUCN brings together 83 states, 108 government agencies, 766 non-governmental organisations, and around 10,000 experts and scientists from countries around the world.

IUCN is the most well-known system for classification of protected areas and is also adopted in Romania. As a result of discussions and consultations in this field, six categories of protected areas were established in the 1990s:

1. Category Ia - strict natural reservation 2. Category II - national park 3. Category III - natural monument 4. Category IV - area of species / habitat management 5. Category V - natural park, protected marine area (landscape) 6. Category VI - protected area with managed resources

National Parks belong to Category II with the aim to:

• set aside “large natural or near natural areas and large-scale ecological processes, along with the complement of species and ecosystems characteristic of the area, which also provide a foundation for environmentally and culturally compatible spiritual, scientific, educational, recreational and visitor opportunities” (IUCN, IUCN.org). The primary objective is to “protect natural biodiversity along with its underlying ecological structure and supporting environmental processes, and to promote education and recreation”2.

Other IUCN agreed objectives for national parks are:

• To manage the area in order to perpetuate, in as natural a state as possible, representative examples of physiographic regions, biotic communities, genetic resources and unimpaired natural processes; • To maintain viable and ecologically functional populations and assemblages of native species at densities sufficient to conserve ecosystem integrity and resilience in the long term; • To take into account the needs of indigenous people and local communities, including subsistence resource use, in so far as these will not adversely affect the primary management objective;

2 https://www.iucn.org/theme/protected-areas/about/protected-areas-categories/category-ii-national-park

5 • To contribute to local economies through tourism.

According to IUCN Category II protected areas are essentially natural systems or in the process of being restored to natural systems. IUCN states that “Category II areas should be more strictly protected where ecological functions and native species composition are relatively intact”. Surrounding landscapes (outside the protected category II - the national park - area) can have varying degrees of consumptive or non-consumptive uses but should ideally serve as buffers to the protected area.

Management is focused on maintaining a whole ecosystems and their ecological integrity at ecosystem scale, not just single habitats and/or individual species. “Category II provides large- scale conservation opportunities where natural ecological processes can continue in perpetuity, allowing space for continuing evolution”, IUCN clarifies.

IUCN accepted national parks have at least 75% non-intervention zones or an IUCN approved and timed plan to reach this target. “The primary management objective must be applicable to at least 75% of the protected area (and the remaining area must be compatible with the primary purpose of conservation)” (Global Protected Areas Programme - Protected areas - achieving quality, IUCN and WCPA)3.

National parks shall also “support compatible economic development, mostly through recreation and tourism, that can contribute to local and national economies and in particular to local communities”.

Well managed and IUCN accepted national parks only allow controlled (and limited for a period of time) activities interfering with natural processes when it supports conservation objectives, such as restoring degraded areas, ecologically based conversion of non-native monocultures into more natural forest ecosystems or fighting invasive species.

Measures supporting human security, including infrastructure protection, flood and avalanche prevention may be allowed. Economical activities in national parks are limited to recreation, nature tourism and ecological eduction. In case of natural calamities or the outbreak of diseases in a

3 cmsdata.iucn.org/downloads/uicn_categoriesamp_eng.pdf

6 park, natural processes should be allowed to follow their course.

In regards to the needs of indigenous people and local communities, including subsistence resource use, IUCN clearly states that these must not adversely affect the primary management conservation objective.

Conclusion:

• Logging of Europe’s last primeval forests in Romania’s national parks is clearly violating these IUCN based standards and principles. • Industrial forest logging in national parks (IUCN category II) is not compatible with international standards (regardless of whether this takes place in core zones or in buffer zones). The conservation objectives of the category II protected area are also valid in “buffer zones” and logging should not take place in these zones.

Radoteasa valley, Domogled National Park: Large area of primeval forest, partly not protected. Logging started in summer 2017. The rest must be preserved now. © Matthias Schickhofer

7 5. STATUS OF THE NATIONAL PARKS IN ROMANIA

Romania has thirteen national parks. Călimani, Cheile Bicazului-Hasmas, Rodna Mountains, Piatra Craiului, Cozia, Buila-Vânturariţa, Retezat, Defileul Jiului, Domogled-Valea Cernei, Semenic-Cheile Carasului, Cheile Nerei-Beusnita, Măcin Mountains and Ceahlau. Their forested areas represent only 1% of Romania's land surface. Large areas of forests in these parks are more degraded today than before they were founded as a national park. Primeval and natural forests immediately adjacent the national parks had also been deliberately excluded from protection in order to be keep them available for exploitation.

The average proportion of areas of non-intervention in Romania’s national parks is around 58%. In most cases the core zones are fragmented and national parks appear like a “piece of Swiss cheese”.

Only one national park, Defileul Jiului, reaches the IUCN protection objective of at least 75% natural development. In seven parks the strictly protected areas are smaller than 55%. Four parks with large areas of primeval forests, Cozia, Domogled-Valea Cernei, Semenic-Cheile Carasului and Cheile Nerei-Beusnita, have cores zones smaller than 55% of the park’s total surface. In all the national parks, large and important areas of old growth and primeval forests have been excluded from the core zones. The “buffer zones” of these parks show clear evidence of logging and subsequent national park degradation.

In fact, the “buffer zones” do not ensure protection of important forests but rather they attract the attention of the logging industry for exploitation, meaning they are almost “sentenced to death”. These forests often exhibit ecological quality that would cause great enthusiasm with conservationists and scientists anywhere else in the EU.

National parks elsewhere sometimes do not meet the IUCN 75% rule yet, but they may at least have a structured and binding plan to achieve this target percentage of strict protection in the future. The management plans of almost all Romania’s national parks do not contain a roadmap of how to reach the 75% non-intervention area target.

Local communities do not substantially benefit from commercially exploited timber in national parks. Forest works are often conducted by logging companies and teams from outside the region, including from abroad. Workers are paid poorly and they live in very primitive conditions in the 8 logging camps. In other words, they are pawns in the game of large commodity industrial logging and timber processing companies.

Timber from national parks often reaches foreign processing firms that have developed massive capacities well above sustainable cutting levels for their intakes from Romania 4 .

Semenic National Park. © Matthias Schickhofer

6. NATIONAL PARKS AND SUSTAINABLE ECONOMY

There is a growing trend in tourism towards experiences of unspoilt nature and wilderness encounters, as counter development to urbanisation and digitalisation. Many Europeans fly to distant places such as Canada or Patagonia every year to experience time in wild nature. Romania still hosts gorgeous wilderness remains and primeval landscapes, more than any other EU member state outside Scandinavia.

This offers a unique opportunity to foster and develop local economies in Romania’s rural regions through nature protection, not exploitation. Numerous studies over decades clearly demonstrate that national parks in the rest of Europe are a major economical contributor to local, regional and national economies. However, they must be valued by their governments, comprehensively resourced and promoted, allowing both the public and private sectors to invest in quality infrastructure that will attract and sustain visitors, including good accommodation, fine gastronomy and interesting outdoor experiences like hiking trails leading to magical places. To enable people to find these offers, governments must upgrade services and resource promotion of nature based

4 https://youtu.be/H9vgZjMjAmk

9 tourism including through best practice, multi language web-portals. Good examples are the Bavarian Forest National Park in Germany or Kalkalpen National Park in Austria.

Romanian national parks are underfunded and gross mismanagement prevents them from being optimally managed for conservation purposes. Some national parks like Semenic-Cheile Carasului do not even have a visitor centre. This park is home to the largest virgin beech forest within the EU (approximately 5000 hectares), which would be a major drawcard for forest lovers, photographers, hikers and anybody who likes to visit nature. Most parks do not have any information in foreign languages making it even harder to draw interest from international visitors.

Conservationists and local owners of pensions complain that Romanian national park management often do not show sincere interest in environmental education and tourism. This is due to lack of funds, lack of training, corruption and the dominant exploitative logging paradigm, both legal and illegal. However, national parks are a major source of pride for most countries and can be developed as tourism engines preserving nature and massively contributing to the economic welfare of local communities.

There are still many areas in Romania that could be designated as national parks (Ţarcu Mountains, Făgăraş Mountains etc.) from a conservation and scientific point of view. But even though they have been promoted as such, including by the Romanian Academy, the Ministry of Environment has rejected moves to establish more national parks which should have protected more Romania’s precious natural heritage.

The largest primeval beech forest within the EU: Semenic National Park © Matthias Schickhofer

10 7. GOOD PRACTICE EXAMPLES

HOW ARE NATIONAL PARKS MANAGED IN OTHER COUNTRIES? Examples from Austria and Germany.

Modern and well run national parks clearly follow the IUCN conservation criteria, receive basic funding from public (state) budgets and are managed independently from resource extraction and exploitation interests.

KALKALPEN NATIONAL PARK / AUSTRIA

Established: 25th July 1997 Size: 20,850 hectares Zones: 89% nature (wilderness) zone, 11% conservation zone Property ownership: 88% Republic of Austria (formerly managed by Austrian State Forests / Österreichische Bundesforste / ÖBF), 11% private ownership, 1% municipality Internationally accepted by IUCN as national park (category II protected area) since 1998 Website: www.kalkalpen.at

The national park’s foundation is an agreement between the State and the Province of Upper Austria. A provincial law (“Nationalparkgesetz”) gives a clear framework for the park and its further development. Basic funding of the parks administration and maintenance is provided by both the Austrian State and the Province of Upper Austria (50% each). The national park management reports to the Provincial Government.

The Austrian Federal Forests ÖBF who managed most of the park’s forests before it was designated as a protected area now deliver defined services for the management of the park (road and trail maintenance, game management, bark beetle management, visitors management etc.), but they do not conduct any commercial forestry or hunting any more. ÖBF are also not in charge of the parks leadership as this is with the national park director who is hired by the Province / State.

Most of the park’s forests have been “managed” in the past, and hence only a small area of virgin forest remains.. However, Kalkalpen National Park is becoming the largest forest wilderness of the Alps. This includes strict non-intervention with natural disturbances such as storm fells, avalanches and bark beetle outbreaks. Bark beets calamities are monitored, but active management (debarking, removal of affected trees) only is applied in a small strip along the park’s boundaries to avoid damage to the surrounding forest areas. The national park was granted an exception from Austria’s legal obligation to immediately remove affected trees.

The park has a large visitor centre with exhibitions, runs a hotel and pasture huts, and provides guided tours as well as numerous hiking trails. The national park is further developing its nature tourism programmes in order to foster thelocal economy.

BAYERISCHER WALD NATIONAL PARK / GERMANY

Established: 7th October 1970 (the first national park in Germany) Size (1970): 13,229 ha Zones (1970): 71,2% nature zone (no intervention), 26,5% buffer zone (no commercial forestry, but selective bark beetle management possible); plan to stepwise reach 75% core zone. Enlargement: 1st August 1997 Size (2017): 24,217 hectares (old area plus 11,000 ha; state forest) Website: www.nationalpark-bayerischer-wald.de/

11 Zones and development plan (2017): 72,6 % of the enlargement area will be turned into nature zone and more areas were added to the core zone in November 2017. On the rest of the development zone (8,75 % of the park) bark beetle management is still possible until 2027 (limited to “Hochlagenwald”; spruce plantations, higher elevations). In 2017 the core zone covers 16,477.3 ha (= 68,03 %) of the parks surface. In 2027 the national park will reach the IUCN-target of 75% core zone.

A severe thunderstorm in August 1983 caused massive wind throws in secondary spruce stands mainly on the hilltops and highlands of the park. However, although there was widespread fear the the storm felled areas will not regenerate so easily, Hans Eisenmann, a former minister of the federal state of Bavaria, decided not to clear up the wind throw areas in the then reservation zone of the national park but to leave them for natural forest development. Only in a slim strip along the boundaries of the park bark beetle affected forest will be managed to avoid potential damage to neighbouring forests. The motto of the park is “Let nature be nature”.

The non intervention policy led to conflicts within local population and among foresters, the national park was doing pioneering efforts. In the old part of the park, the strict non intervention regime was not weakened.

However, in the enlargement area bark beetle management was allowed as a compromise to get approval for the park expansion. This led to conflicts, as bark beetle management was conducted partly in a non sustainable way (clearings of affected spruce monocultures).

Nevertheless, the outstanding conservation value of Bavarian Forest National Park have been maintained through good management and on very large areas of the park, the bark beetle investments were not cleared, but left to natural processes. This was the first time in central Europe that a large bark beetle calamity was not instantly responded to by clearing. Many thousands of dead trees remaining on the slopes helped to stimulate intensive regeneration of a biodiversity rich secondary natural forest. The dead trees provided shadow and soil protection, stored water and have kept game out of young stands. The Bavarian Forest National Park proves that even in a secondary spruce forest a major disturbance such as bark beetle outbreak is not a catastrophe for nature, but rather helps to re-establish more natural and more ecologically stable forest development.

Natural forest renewal after bark beetle calamity: Bavarian Forest. © Matthias Schickhofer

12 BERCHTESGADEN NATIONAL PARK / GERMANY

Established: August 1, 1978 Size: 210 square kilometres Ownership: Federal state of Bavaria. Core zone: 75 % Website: www.nationalpark-berchtesgaden.de/

The national park has been accepted by IUCN. At least 75% of the park’s surface is designated as a nature zone, where exploitation and resource extraction is banned completely. In the so called “Pflegezone” (management zone; less than 25%) traditional servitude rights of local communities are respected and grazing on pastures and traditional fishery is still possible. Each year around 1.5 million guests visit Berchtesgaden National Park, so the park contributes substantially to the economic welfare of the region.

In the area a network of some 260 km of walking and mountain trails has been established. The National Park Centre "Haus der Berge" in Berchtesgaden serves is central information point and helps to channel the majority of tourists.

Also outside the national park the region provides good practice examples: the Berchtesgaden forest district of Bavarian State Forests follows a comprehensive integrated nature conservation concept, which includes protection old growth forests in the mountain area in the whole district5. Website:

KELLERWALD-EDERSEE NATIONAL PARK / GERMANY

Established: January 1, 2004 Size: 5,735 ha Zones: 90% nature (wilderness) zone Website: www.nationalpark-kellerwald-edersee.de/

The first national park in German federal state Hessen protects one of the last large beech forests in Central Europe which is neither dissected by roads nor settlements. The park’s primary conservation objective is to ensure that undisturbed development and dynamics of the natural and near-natural ecosystems on more than 90% of the area (process conservation).

It fulfils the central criterion for the international recognition in category II by the International Union for the Conservation of Nature and Natural Resources (IUCN). It hosts large beech forest areas, including several stands of old growth beech and oak forest, which are extremely rare in Germany today.

90% of the park’s surface has been taken out of any exploitation use, tomorrow’s wilderness is developing also in formerly managed forest areas.

Tourism is welcomed on the hiking trails, such as the popular “Urwaldsteig”, a multi-day trekking route directing people to magical old growth forest locations.

At its 35th session in Paris on 25 June 2011, the World Heritage Committee decided to inscribe the “Ancient Beech Forests of Germany” in the World Heritage List, which is now an additional drawcard for the park.

5 /www.baysf.de/de/wald-schuetzen/naturschutz.html

13 8. GROUND CHECK: ROMANIA’S NATIONAL PARKS IN IMAGES

Domogled - Valea Cernei National Park, at the border of Iauna Craiove UNESCO World Heritage site © Agent Green / Andrei Ciurcanu

Domogled - Valea Cernei National Park, Radoteasa valley - the last untouched valley system of the park. In spring 2017 logging was approved by the forest authority. © Matthias Schickhofer

9. WHAT NEEDS TO BE DONE?

EURONATUR AND AGENT GREEN CALL ON THE ROMANIAN GOVERNMENT TO TAKE IMMEDIATE ACTION:

• Adaptation of the legal framework for harmonisation with IUCN requirements: overall superiority for nature conservation objectives in all national park territories, phased growth plan to reach at least 75% non-intervention zones.

• Take over the administration of all national parks by the State, establishment of independent and modern national park management in all Romanian parks following best practice examples (Germany, Austria, Sweden etc.).

• Ensure adequate public funding for and promotion of Romania’s national parks.

• Re-define the boundaries of national parks based on rigorous scientific criteria, include all remaining old growth/primeval forests in Romania’s national parks in core zones, immediate ban of commercial logging in all parks.

• Establishment of new national parks including in Făgăraş and Ţarcu.

• Develop and implement an integrated national ecotourism strategy to ensure the preservation and promotion of national parks, to improve services and provide support to local communities.

Further information:

„Out of Control“ is part of the campaign „Save Paradise Forests“. This international campaign aims to protect the most valuable old-growth forests of the Carpathian Mountains, particularly in Romania. It is jointly coordinated and carried out by EuroNatur and Agent Green. Read more at www.saveparadiseforests.org

AGENT GREEN is a romanian non-governmental non-profit organisation dedicated to protecting the environment, founded in 2009 in Romania for the purpose of preserving biodiversity. The organisation has an affinity for investigating environment crimes, strategically exposing these crimes and promoting solutions for protecting nature and ensuring the well-being of future generations.

Contact Agent Green: E-Mail: [email protected]

EuroNatur is a non-profit foundation which stands up for the conservation of the European nature heritage on many different levels, e.g. via special species protection projects, renaturation measures, and site protection as well as political lobbying activities or environmental education. EuroNatur always cooperates closely with regional partner organisations and local residents and creates solutions that allow humans to live and work in harmony with nature.

Contact Euronatur: Westendstraße 3 D-78315 Radolfzell Germany E-Mail: [email protected], phone: +49 (0)7732 - 92 72 0